20th February 2014

To,
Sh. Pramendra Singh,
Insp./ I.O.,
PS: Nihal Vihar,
Delhi-41

Subject: Case FIR No. 61/12 u/s 420/468/471 IPC, PS: Nihal Vihar, Delhi

Respected Sir,
This is in reference (No. 80/ SHO/ Nihal Vihar, Delhi, dated, the 7/01/2014)
to Notice u/s 91, Cr.P.C. served upon the undersigned wherein a request was
made by your good office to verify the transaction.

1. The details of the transaction with Sh. Nishan Singh Bhatti and Sh. Pawan
Kumar are as follows:
(i) That Rs. 60,00,000 (Rupees Sixty Lacs only) was paid in cash by Sh.
Nishan Singh Bhatti and Sh. Pawan Kumar (second party) to the
undersigned (first party) on 22.08.2013 and a Memorandum or
Understanding (MoU)/ Settlement Deed was executed wherein it was
stated that the documents relating to the property would be executed in
favour of the second party on payment of the balance amount of Rs.
18,00,000 (Rupees Eighteen Lacs only).
(ii)That Rs. 18,00,000 (Rupees Eighteen Lacs only) i.e. the balance
amount was paid in cash by Sh. Nishan Singh Bhatti and Sh. Pawan
Kumar (second party) to the undersigned (first party) on 03.09.2013,
and documents were executed in favour of by Sh. Nishan Singh Bhatti
and Sh. Pawan Kumar (second party) on the same date i.e. 03.09.2013.

2. The Passport No. of the undersigned is “J5432423”.

Thanking you.
Akwinder Kaur
W/o Devender Singh
31 Sion Road, Pine City,
Executive Village,
Barangay San Roque,
Anti Polo Manila Philippines
M. 00639163298472
 IN THE HIGH COURT OF DELHI AT NEW DELHI

CRIMINAL MISC. (MAIN) NO. 1474 OF 2014

IN THE MATTER OF:

Sh. Nishan Singh Bhatti & Ors. …. Petitioners

Versus
STATE (GOVT. OF NCT DELHI) & Ors. …Respondents

INDEX

Sl. No. Particulars. Pages.

1. Affidavit

(S.K. Pabbi) (Shikha Roy)

(Surinder Singh) (Ajay Kumar Singh)

Advocates for the Respondent
301, Lawyers, Chamber Block-III,
Delhi High Court, New Delhi-110003
 IN THE HIGH COURT OF DELHI AT NEW DELHI
CRIMINAL MISC. (MAIN) NO. 1474 OF 2014

IN THE MATTER OF:

Sh. Nishan Singh Bhatti & Ors. …. Petitioners

Versus
STATE (GOVT. OF NCT DELHI) & Ors. …Respondents

AFFIDAVIT
Affidavit of Ms. Akwinder Kaur. w/o Late Sh. Davinder Singh
R/o House No. 175 Kishanpura, Gali No. 5, Phagwara, Punjab and
presently residing at House No. 31, Sessions Road, Pine City,
Executive Village, Antipolo, Manila, Philippines, do hereby solemnly
affirm and declare as under:

1. That the deponent is respondent No. 2/complainant in this

matter as such she is well conversant with the facts and
circumstances of the case hence she is competent to swear
this affidavit.

2. That at the outset the deponent submits that the respondent

No. 3 in this case i.e. father-in-law of the respondent No. 2,
has illegally sold the property in question to the petitioners
herein on the basis of fictitious power of attorney of the
husband of respondent No. 2.

It is further submitted that the husband of respondent No. 2

was shot dead in Philippines on 16.12.2007 and during his life
time, her husband executed a Registered Will dated
26.03.2006, bequeathing all property either in India or out side
of India (including property in question) to the deponent. When
the deponent came to know about the sale of property in
question then she lodged a complaint against the accused
persons i.e. her father in law i.e. respondent No. 3 and the
petitioners herein.

3. That it is submitted that the deponent entered into a

compromise/settlement dated 22.08.2013 with the petitioners
 herein and received a sum of Rs. 78 lacs as settlement
amount/Sale consideration in respect of property in question.

4. That consequently on 02.09.2013, the deponent executed the

title document i.e. Agreement to Sale, Receipt, Possession
Letter, G.P.A., Affidavit, Will and Indemnity Bond in favour of
petitioners with regard to property in question.

5. That in the aforementioned circumstances, the deponent has

no grievance specifically against the petitioners herein and she
would have no objection if the proceeding pending against
petitioner No. 1 to 4 arising out of FIR No. 61 of 2012
registered at PS Nihal Vihar, New Delhi may kindly be quashed
if this Hon’ble Court deems fit.

DEPONENT
VERIFICATION:
I, the above named deponent verified the contents of affidavit
at New Delhi on this day of July 2014 and declare that contents
of affidavit are true and best of my knowledge and belief and nothing
material has been concealed therefrom.

DEPONENT